TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Deduction u/s 80IA was allowed despite delay in filing Form 10CCB due to technical glitches on the Income Tax portal. The form was filed 1 hour 22 minutes after the due date of 31.10.2022. CIT(A) relied on the assessee's statement and allowed the deduction. ITAT held that the delay was beyond the assessee's control and cannot be construed as discrepancy or failure on their part. The prescribed form was available before AO when return was processed. Case laws on exemption notifications and CBDT Circular 9/2015 regarding delay in filing refund claim and carry forward losses were deemed irrelevant. As the form was filed before the due date of return filing with a slight delay, and the delay was not due to negligence or inaction by the assessee, the deduction was allowed in the interest of justice. The delay was not attributed to the assessee, hence no penal action was imposed.
Deduction u/s 80IA was allowed despite delay in filing Form 10CCB due to technical glitches on the Income Tax portal. The form was filed 1 hour 22 minutes after the due date of 31.10.2022. CIT(A) relied on the assessee's statement and allowed the deduction. ITAT held that the delay was beyond the assessee's control and cannot be construed as discrepancy or failure on their part. The prescribed form was available before AO when return was processed. Case laws on exemption notifications and CBDT Circular 9/2015 regarding delay in filing refund claim and carry forward losses were deemed irrelevant. As the form was filed before the due date of return filing with a slight delay, and the delay was not due to negligence or inaction by the assessee, the deduction was allowed in the interest of justice. The delay was not attributed to the assessee, hence no penal action was imposed.
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